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One focus of the Make America Healthy Again (MAHA) Commission report is children's exposure to environmental chemicals and its link to health risks, particularly cumulative risk and chronic disease. Despite the evidence showing that the current approach to regulating pesticides and other chemicals fails to protect children's health, the report fails to take the next step—of promoting organic production and land care. Although the registration of pesticides is under the purview of the U.S. Environmental Protection Agency (EPA), the U.S. Department of Health and Human Services (HHS) can promote organic practices and protect children's health from pesticides through the setting of pesticide tolerances on food, or allowable levels of residues. 

>> Tell HHS Secretary Robert F. Kennedy, Jr. to revise the memorandum of agreement with EPA on pesticide residues in food and set protective levels.

The MAHA report points to:

• The cumulative load of thousands of synthetic chemicals that our children are exposed to through the food they eat, the water they drink, and the air they breathe may pose risks to their long-term health, including neurodevelopmental and endocrine effects. 
• Over 40,000 chemicals are registered for use in the U.S. 
• Pesticides, microplastics, and dioxins are commonly found in the blood and urine of American children and pregnant women—some at alarming levels. 
• Children are particularly vulnerable to chemicals during critical stages of development—in utero, infancy, early childhood, and puberty. Research suggests that for some chemicals, this cumulative load of exposures may be driving higher rates of chronic childhood diseases. 

And finds, “[I]n 2025—28 years after EO 13045 [Protection of Children from Environmental Health Risks and Safety Risks] was signed—childhood health has largely worsened, and there is a growing concern about the link between environmental health risks, particularly cumulative risks, and chronic disease. Furthermore, in the past nearly 30 years, the chemicals children are exposed to have grown—and no country fully understands how the cumulative impact of this growth impacts health.” 

The report cites research showing adverse effects of pesticides, including cancers, liver inflammation, metabolic disturbances, endocrine disruption, and birth defects.*** Despite finding that the vast majority of food samples are “compliant with federal standards,” the report does not conclude that federal regulation of chemicals is inadequate.  

Registration of a pesticide that is expected to result in residues on foods requires non-zero tolerances for pesticide residues on those foods. A 1970 memorandum of understanding (MOU) issued upon the establishment of EPA divided responsibilities for pesticide tolerances under the Federal Food, Drug, and Cosmetic Act (FFDCA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) between EPA and the U.S. Department of Health, Education, and Welfare (now HHS).

That MOU, which gave most responsibility for setting allowable pesticide residues in food to EPA, is out of date for the following reasons:

1. While moving pesticide registration to EPA from the U.S. Department of Agriculture (USDA) should have, in theory, changed the bias of regulators that favored approval of registrations, in fact, it left a presumption of need that has crippled the pesticide program.  

2. With the ongoing expansion of organic production, that presumption is more questionable than ever. EPA still lacks the expertise to judge need ("benefits of registration"). 

3. EPA's established process for determining health effects depends on data developed by and submitted by the industry without public oversight. This constitutes a strong conflict of interest. 

4. The risk assessment process that EPA uses to determine allowable harm from pesticide exposure does not consider full formulations of pesticide product ingredients, chemical mixtures, those with preexisting conditions and/or vulnerabilities, and critical health outcomes, such as endocrine disruption. 

>> Tell HHS Secretary Robert F. Kennedy, Jr. to revise the memorandum of agreement with EPA on pesticide residues in food and set protective levels.

The growth of organic production demonstrates that the need for pesticides can no longer be presumed. The market for organic food has consistently increased in recent years. U.S. sales of certified organic products hit a record high of $71.6 billion in 2024. The evidence shows that shifting to organic production has benefits for farmers, consumers, and the environment.  

While productivity in organic systems may sometimes be lower than in chemical-intensive agriculture, the difference depends on the crop. The productivity of an organic system is a result of a complex interaction among cultivation practices, cover crops, crop rotations, and manuring—all of which result in improved soil health, microbial diversity, and ecosystem services. Microbial diversity reduces the need for irrigation and chemical inputs by improving water retention, enhancing nutrient uptake, and enhancing resistance to pests and disease, thus resulting in long-term savings to the farmer. 

Furthermore, reduced productivity does not imply reduced profitability because organic products command a significant price premium. Consumers are willing to pay more for organic food because of the health and environmental benefits. As consumers seek more healthful food, they also create a greater demand for organic products. These benefits are real. A systematic review of the scientific literature showed that with even six months of an organic diet, “A significant inverse relationship between organic food consumption and cardiometabolic risk factors, including obesity, diabetes mellitus, hypertension, and hyperlipidemia was observed in the majority of prospective studies.”  

HHS should, based on findings in the MAHA report, propose a new MOU with EPA: 

1. The need for the pesticide should be established by agronomists familiar with organic production methods, subject to a public comment process. Successful cultivation of the crop using organic methods should be considered a rebuttable presumption that the pesticide is not needed and, therefore, residue tolerances should be set to zero. 

2. Health effects of the pesticide should be established by HHS based on research published in the open literature and reviewed by National Institutes of Health (NIH) scientists. Establishment of a pesticide residue tolerance requires findings on (a) the threatened harm from exposure to the pesticides under consideration for allowance or use, taking into account both data on acute and chronic effects, including endocrine disruption, obtained through regulatory review and an assessment of the independent, peer-reviewed scientific literature; (b) the effect or effects to those with elevated risk factors, including but not limited to children, older people, those with preexisting medical conditions, and organisms in ecosystems that support health; and (c) the number of those who will potentially experience adverse health effects as a result of the decision. 

3. If the agencies agree that registration of the pesticide is needed and that no significant health effects will result, a proposal for a tolerance for the pesticide and its metabolites, with supporting research, must be published in the Federal Register with a 120-day comment period. 

This action would be a first step toward the goal stated in the MAHA report: “The current regulatory framework should be continually evaluated to ensure that chemicals and other exposures do not interact together to pose a threat to the health of our children."

>> Tell HHS Secretary Robert F. Kennedy, Jr. to revise the memorandum of agreement on pesticide residues in food and set protective levels. 

The target for this Action is the U.S. Department of Health and Human Services.

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↪️ For more information, please stay tuned for the Daily News post on June 2, 2025.

*** Recent coverage by the New York Times, originally reported by NOTUS, has brought into question the reliability of certain scientific studies cited in the MAHA report over allegations of artificial intelligence use and the generation of fake citations. We urge the public to reference Beyond Pesticides' Pesticide-Induced Diseases Database (PIDD) for the independent, peer-reviewed scientific research for references on most of the health effects of pesticides cited in the MAHA Commission report.